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e in the West Palm Beach Division of the Southern District of Florida, for making misrepresentations during a prior sentencing proceeding. In fact, Stephanie Thacker, a former deputy to CEOS Chief Drew Oosterbaan, has stated that she knew of no other case like this being prosecuted by CEOS. 3 08-80736-CV-MARRA
re. When asked, the closest case suggested by the prosecutors was United States I Boehm—and it hardly could differ more from Mr. Epstein's case. In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine base to minors, in violation of 21 U.S.C. §§ 846, 841(a)(1), and 859(a)
ral prosecutors have pursued under the federal sta tes at issue here. When asked, the closest case suggested by the prosecutors was United States I Boehm—and it hardly could differ more from Mr. Epstein's case. In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine base
bmissions include: a summary of the irregularities and misconduct that occurred during the federal investigation; a letter from former CEOS attorney Stephanie Thacker that responds to CEOS's assessment of its limited review of Mr. E stein's case; and a point-by- point rebuttal to First Assistant United States Atto
e. When asked, the closest case suggested by the prosecutors was United Stares v. Boehm—and it hardly could differ more from Mr. Epstein's case. In Boehm, the defendant was charged with conspiracy to distribute cocaine and cocaine base to minors, in violation of 21 U.S.C. §§ 846, 841(a)(1), and 859(a)
ion of a firearm, in violation of 18 U.S.C. § 922(g)(1); and sex trafficking of children in violation of 18 U.S.C. §§ 371 and 1591. United States v. Boehm, Case No. 3:04CR00003 (D. Alaska 2004). Boehm's actions, unlike Mr. Epstein's, also had a strong interstate nexus: Boehm purchased and distributed
As all prosecutors know, there are no perfect witnesses. Particularly in Cases involving exploited children, as one member of your defense team, Ms, Thacker, surely knows from her work at CEOS, it is not uncommon for victim-witnesses to give conflicting statements. The prosecutors are in the best position
impartial, independent representative be. appointed to administer that fund. Notably, such a restitution fund was created in a federal case, U.S. v. Boehm, Case No. 3:04CR00003 (D. Alaska 2004). The federal prosecutors here rejected this idea, and they insisted that an attorney representative, paid for
Entities connected to both Stephanie Thacker and Boehm

Jeffrey Epstein
PERSON
Ken Starr
PERSON
Jay Lefkowitz
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSONthe Southern District
LOCATIONGerald Lefcourt
PERSONLeon Black
PERSONRoy Black
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Alice Fisher
PERSONKirkland & Ellis LLP
ORGANIZATION
A. Marie Villafana
PERSONJack Goldberger
PERSONSanchez
PERSON
Prince Andrew
PERSON
Guy Lewis
PERSON
Drew Oosterbaan
PERSON